Privacy Policy

Privacy Policy

Last Updated: [November 11, 2025]

1. SCOPE AND ACCEPTANCE

This Privacy Policy describes how Tarantín (hereinafter, "Tarantín" or "The Company") collects, uses, protects, and shares the personal information of its Users (Buyers, Sellers, and Visitors), in compliance with the constitutional right to privacy and the Law on Data Messages and Electronic Signatures.

By registering or using Tarantín's services, the User gives their express and informed consent to the collection, storage, and processing of their personal information in accordance with this Policy.

2. PERSONAL INFORMATION WE COLLECT

We collect information necessary for the operation of the Marketplace and, especially, for compliance with the Fintech/AML regulations of the internal Digital Wallet.

A. Site View.

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as "Device Information."

We automatically collect Device Information using the following:

• Cookies: Data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

• Log Files: Track actions occurring on the Site and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• Web Beacons, Tags, and Pixels: Electronic files used to record information about how you browse the Site.

• Device: IP Address, browser type, operating system, unique device identifiers.

• Log Files: Pages visited, time and duration of visit, search terms, and clicks made.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, if applicable), email address, and phone number. We refer to this information as "Order Informa¹tion."

B. Obligation of Verification (Role Distinction):

Account Verification and KYC Levels:

• Sellers (Stores) - Mandatory Verification: Any User who wishes to list and sell products must mandatorily complete the Store Verification process (High-Level KYC). The User must provide identification documentation (ID/RIF, Selfie with document) and accepts that the public PROFILE IMAGE associated with the Seller's account MUST REASONABLY MATCH the person who appears in the identity document and in the verification Selfie. Tarantín reserves the right to reject verification or suspend the account if there is a notorious inconsistency between the documented identity and the public profile image.

• Buyers (General Users): Registration and purchasing are available for Unverified Users. However, to access the full functionality of the Digital Wallet (including the P2P process (if applicable) and high transactional limits) and to qualify under the Buyer Protection Guarantee, Tarantín reserves the right to require verification (Medium-Level KYC).

C. Assumption of Risk Clause (Trading with Unverified Parties)

Assumption of Risk based on Verification Level:

• Trading with Unverified Users: When a verified Seller agrees to process a transaction with a Buyer who has not completed the full verification process, both parties consciously assume a higher transactional risk.

• Limitation of Liability: In case of fraud, non-compliance, or dispute involving an Unverified User, the User assumes that the limited counterparty data might hinder the resolution of the case. Tarantín's responsibility for mediation does not extend to guaranteeing the identity of parties who choose not to verify.

• Restrictions: Tarantín reserves the right to impose lower transactional limits or nullify the Buyer Protection Guarantee in transactions where the Buyer is not fully verified, notifying this clearly on the payment interface.

D. Registration and Profile Information (High-Level KYC)

For Mandatory Store Verification (Sellers), Tarantín collects and stores the following sensitive information:

• Identity Card or RIF (Front and back image of the document).

• Proof of Life (Selfie): Photograph of the legal representative holding their identity document.

• Corporate documentation (in the case of a legal entity).

• Biometric Consistency Verification: The Public Profile Image uploaded by the Seller will be cross-referenced with the Selfie and the identity document provided to verify the consistency of the identity. This profile image becomes sensitive data associated with KYC.

E. Transactional and Financial Information (AML) (if applicable).

Given the Fintech operation (USD-Anchored Virtual Currency and P2P), we collect:

• Transaction Details: History of purchases, sales, amounts, date, time, and shipping/billing addresses.

• Wallet Data: Balances, history of top-ups (inflows of bolivars via P2P), and withdrawals (outflows), and identifiers of associated bank accounts for cash-in/cash-out operations.

• Due Diligence (Fintech): We may request documents that prove the Source of Origin of Funds (e.g., proof of employment, tax return) in compliance with the LCDOFT for high-value operations.

2. How Do We Use Your Personal Information?

We use the collected information for the following essential and legal purposes:

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

• Communicate with you.

• Screen our orders for potential risk or fraud.

• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.²

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your³ IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

3. Sharing Your Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use third-party services for the payment gateway (when applicable) and for shipping. We may also use Google Analytics to help us understand how our customers use the Site; you can read more about how Google uses your Personal Information here: https://policies.google.com/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Tarantín does not sell or rent the personal information of its Users to third parties. We only share your information in the following circumstances, always under confidentiality clauses:

• With the Transaction Counterparty:

  • The necessary information of the Seller (name or business name, RIF, contact number) is disclosed to the Buyer to coordinate delivery and post-sale support.

  • The shipping address and the Buyer's name are disclosed to the Seller.

• Service Providers (Third Parties): With allied companies that perform functions on our behalf (e.g., logistics partners for shipping, data analysis providers, cloud computing services for storage).

• Governmental and Legal Authorities (CRITICAL/If applicable):

  • SUNACRIP / BCV / SUDEBAN: If the regulation of the USD-Anchored Virtual Currency requires it.

  • UNIF / Prosecutor's Office: When required by court order or to comply with the obligations to report suspicious operations (ROS) under the LCDOFT.

  • SUNDDE: In the context of formal consumer protection claims.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

4. Targeted Advertising (Behavioral Advertising)

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s ("NAI") educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by using the following links:

• Facebook: https://www.facebook.com/settings/?tab=ads⁴

• Google: https://www.google.com/settings/ads/anonymous⁵

• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policie6s/personalized-ads

  Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

5. Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

6. Your Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.7

Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our le8gitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United 9States.

7. Data Retention

7.1 Retention (AML Requirement)

We will retain the User's Personal and Transactional Information while the account remains active and for a subsequent period of at least five (5) years after account cancellation, as required by Money Laundering Prevention regulations in Venezuela.

7.2 Security

We use high-level technical, administrative, and physical security measures (e.g., encryption, firewalls, secure storage) to protect information against unauthorized access, loss, or disclosure.

8. Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

9. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@tarantin.app.